How the DGT's position has evolved
Current position
The exemption under article 7.p) of the LIRPF (Personal Income Tax Law) requires that the work be effectively performed abroad for a non-resident entity or a permanent establishment abroad. The physical displacement must be to a country with an analogous tax that is not a tax haven. It is not a requirement that the income be taxed in the destination country, but rather that a tax of a similar nature applies.
The DGT's position remains constant in the interpretation of the exemption for displacement abroad. The rulings confirm that the core is the effective provision of work for a non-resident entity in a country with analogous taxation. No changes in the substantive requirements are observed throughout the sequence.
Analysis based on 25 of 25 rulings with a stated position. Updated 24 September 2026.